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Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 4. ...

STEP CRA Roundtable – June 2014 QUESTION 6. Trust Audit Issues Can the CRA provide an update on the most common audit issues that it finds / reviews regarding trusts? ...

12 June 2012 Roundtable, 2012-0442871C6- STEP CRA Roundtable Question 10- June 2012 CRA Tags 70(5) Principal Issues: Disposition of life estate & imminence of death Position: Comments on valuing a life estate when disposition is deemed by 70(5) Reasons: FMV of interest depends on the facts STEP CRA ROUNDTABLE – June 2012 QUESTION 10 Where an individual has a life interest in a property and the individual dies, the life interest is to be valued without taking into account the imminence of death of the individual. ...

STEP CRA Roundtable – June 2012 Question 14: A taxpayer (“Pensioner”) with no spouse, common-law partner or children had retired before her death and had commenced drawing a monthly retirement pension, with a guarantee period, from the defined benefit registered pension plan (“RPP”) of which she was a member. ... In this regard, can CRA comment on the following wording found in paragraph 15 of Interpretation Bulletin IT-212R3 Income of Deceased Persons – Rights or Things (“IT-212R3”): “There may be exceptional cases where a pension fund or plan provides for voluntary withdrawal of contributions by an individual contributor (possibly with interest and/or employer's contributions) at a time or times other than on retirement or on leaving the employment. ...

STEP CRA Roundtable – June 10, 2016 QUESTION 1. Graduated Rate Estates and Transfers to Testamentary Trusts Created by Will The definition of “graduated rate estate” in subsection 248(1) of the Act requires such an estate to be a testamentary trust and that no other estate is designated as the graduated rate estate of the deceased individual. At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ...

STEP CRA Roundtable – June 10, 2016 Question 9. Support for U.S. foreign tax credit claims Recently, many practitioners and / or Canadian taxpayers have been receiving requests from the CRA to obtain a transcript from the United States Internal Revenue Service to the extent that foreign tax credits were claimed in respect of US tax paid that corresponds to the filing of a US tax return. ...

IFA 2018 International Tax Conference Canada Revenue Agency Roundtable Question 3 – Interaction of subsection 91(5) and subparagraph 93.1(2)(d)(i) Subsection 93.1(1) of the Income Tax Act (the “Act”) allows some of the foreign affiliate rules, including the rules in section 113 of the Act, to apply to corporate structures that include partnerships. ... John Meek / Sherry Thomson 2018-074917 May 16, 2018 ...

Reasons: 1) See below. 2) see below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 14. ... This comment was made upon considering that: subparagraph (a)(i) of the definition of “split income” in subsection 120.4(1) includes in computing income an amount “in respect of taxable dividends received by the individual in respect of shares of the capital stock …”; subsection 104(19) deems the amount so designated to be a taxable dividend received by the taxpayer (the preferred beneficiary) for all purposes of the Act other than Part XIII; and there is no legislated exclusion from TOSI for dividends designated under subsection 104(19). ii) This position is not a new interpretation. ...

Reasons: Articles 22(2) and 23(2)(a) of the Canada-Australia Treaty operate in conjunction with subsection 126(1) of the Income Tax Act to provide a foreign tax credit. 2020 STEP CRA Roundtable – November 26, 2020 Question 4- Foreign Tax Credit Under the Income Tax Act (the “Act”), the Canadian tax base extends to tax a non-resident on the capital gain realized on a disposition of taxable Canadian property (“TCP”). ... John Meek / Komal Patel November 26, 2020 2020-083800 ...

Reasons: See analysis below. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 7. ... Paragraph 248(25)(a) describes a person or partnership beneficially interested in a particular trust as “any person or partnership that has any right … as a beneficiary under the trust to receive any of the income or capital of the particular trust either directly from the particular trust or indirectly through one or more trusts or partnerships.” ...